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Millennium Fund. This document is not intended or written to be used, and cannot be used, by any Investor for the purpose of avoiding penalties that the Internal Revenue Service might seek to impose on such Investor. Each Investor should seek advice based upon such Investor's circumstances from an independent tax adviser. L
td. Cayman Islands exempted company with limited liability formed May 2011 Millennium Strategic Capital LP (Class B Interests) formed July 2011 Millennium USA LP (Class NN-Ill Interests) formed January 1998 Millennium USA LP (Class Interests) formed January 1998 Millennium International Ltd. (Class FF-
uld result to Investors in the AlphaKeys Fund. The AlphaKeys Fund may, from time to time, report tax positions that may be subject to challenge by the Internal Revenue Service (the "IRS"). If the IRS challenges such a position and is successful, there may be substantial retroactive taxes, plus interest and possibly penalti
onnection with its investment. As used in this Memorandum, the following capitalized terms have the following meanings. "Underlying Fund" refers to Millennium USA LP and any intermediate investment vehicles controlled by the Underlying Fund Manager or its affiliates and into which the Underlying Fund directly or
the income taxation of Millennium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an
e entities through which the Portfolio Managers and related personnel invest in their strategies, the "Fund"). Currently, the Feeder Funds are: • Millennium USA LP ("Millennium USA"), a Delaware limited partnership formed in November 1997, which accepts investments from taxable U.S. investors that qualify as "
the income taxation of Millennium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an
e entities through which the Portfolio Managers and related personnel invest in their strategies, the "Fund"). Currently, the Feeder Funds are: • Millennium USA LP ("Millennium USA"), a Delaware limited partnership formed in November 1997, which accepts investments from taxable U.S. investors that qualify as "
Entities connected to both the Internal Revenue Service and Millennium USA LP

JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSONthe State of New York
LOCATION
Federal Reserve
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Samantha Power
PERSON
Julie K. Brown
PERSONthe Securities and Exchange Commission
ORGANIZATION
New York
LOCATION
U.S. Treasury
ORGANIZATION
Marc Rich
PERSON
John F. Kennedy
PERSON
New York State
LOCATIONthe U.S. Investment Company Act
ORGANIZATION
Wilbur Ross
PERSON
United Kingdom
LOCATIONCayman
LOCATION
the Cayman Islands
LOCATION